Personal Information Protection Policy

Monoxer, Inc. provides services related to memory. Since we handle a great deal of personal information in the course of our operations, we have established a personal information management system to ensure that we handle personal information responsibly.

  • Policy 1. We shall specify the purpose of use of personal information as much as possible and handle it appropriately within the scope necessary to achieve that purpose. We shall also take measures to ensure that the information is not used for any other purpose.
  • Policy 2. Personal information shall be acquired in a lawful and appropriate manner.
  • Policy 3. Personal information shall not be provided to third parties without the consent of the individual.
  • Policy 4. In managing personal information, we shall endeavor to take the necessary and appropriate measures to prevent leaks, loss, or damage of personal information, to correct such leaks, loss, or damage, and to otherwise manage personal information safely.
  • Policy 5. In handling personal information, we shall endeavor to ensure that the individual who has provided such information is appropriately involved and that the information is kept as accurate and up-to-date as possible.
  • Policy 6. We shall comply with all laws and regulations regarding the protection of personal information, and we shall also establish and continuously review our internal regulations regarding the protection of personal information.
  • Policy 7. We shall implement and maintain a management system for the protection of personal information, which shall be regularly reviewed and continually improved.
  • Policy 8. The Company shall establish a contact point for complaints and consultations regarding the protection of personal information and shall endeavor to respond appropriately to such complaints and consultations.

◆ Privacy Policy Changes

We reserve the right to change our Privacy Policy at any time, except as otherwise provided by law.

For inquiries regarding personal information, please contact:
E-mail: info@monoxer.com

Monoxer, Inc.
Kotaro Takeuchi
Representative Director & CEO
Established: July 1, 2017
Revised: March 1, 2019

Privacy Policy

Monoxer, Inc. (hereinafter referred to as “Monoxer”), in recognizing the importance of protecting personal information and in compliance with the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”), will strive to appropriately handle and protect personal information in accordance with the following privacy policy (hereinafter referred to as the “Privacy Policy”). Unless otherwise specified in the Privacy Policy, the definitions of terms used in the Privacy Policy shall be in accordance with the provisions of the Personal Information Protection Act.

1. Definition of Personal Information

In this Privacy Policy, personal information shall mean personal information as defined in Article 2, Paragraph 1 of the Personal Information Protection Act.

2. Personal information to be acquired

2.1 The Company acquires personal information, including the following, from users (hereinafter referred to as “Users”) who create IDs (hereinafter referred to as “IDs”) for this service (hereinafter referred to as the “Service”) in order to use the Service provided by the Company:

(1) Information provided by Users to the Company when opening an account on the Service or when updating account information (such as IDs, password, e-mail address, profile information, etc.);

(2) Information regarding Users’ use of the Service, such as Users’ access log, learning history, and memory of the Service;

(3) Voice data and other information provided to the Company in the course of using the Service;

(4) Information provided when processing payment for the Service;

(5) When Users join an organization managed on the Service by a third party that uses the Service, such as a school or company, and after joining such organization (hereinafter referred to as the “Organization” and the person managing the Organization is referred to as the “Organization Manager”), the identification code of the User in that organization assigned to the User by the Organization Manager, information on the affiliation within the organization (school building, course, grade, class, department, etc.), and other information. The information to be acquired shall be limited to the information that Users can confirm on the Service. If the information assigned to a User by the Organization Manager is changed, only the information after such a change shall be acquired, provided that the User can confirm such changes on the Service.

2.2 The Company acquires the following personal information in the course of its business activities:

(1) Information obtained through the Company website, contact with the inquiry desk, and other various inquiries;

(2) Information acquired at events held or participated in by the Company;

(3) Information acquired from business partners;

(4) Information about applicants for employment;

(5) Information about Monoxer officers and employees;

(6) Information on shareholders or share option holders, etc. of the Company.

3. Purpose of Use of Personal Information

Monoxer shall use acquired personal information for the following purposes:

3.1 User information acquired on the application for the Service (hereinafter referred to as the “Application”):

(1) To authenticate and manage Users when registering for the Service and logging into the Service;

(2) To display educational materials, to manage Users’ learning history and memory, and to provide other Services;

(3) To prevent and respond to fraud, etc;

(4) To maintain and manage the Service;

(5) To bill for the Service;

(6) To provide information on the Service and to respond to inquiries, etc;

(7) To analyze information regarding the use of the Service by users for the purpose of improving Monoxer services, investigating problems, developing new services, etc;

(8) To create statistical data related to the Service, processed into a format that does not identify individuals;

(9) To provide the information to academic research institutions such as universities, etc., and to improve Monoxer services and conduct other research in cooperation with such academic research institutions, etc;

(10) To provide support to an Organization if Users join an Organization.

(11) To provide an Organization with Users' learning history on the Service, results of tests, etc. taken on the Service, and memory on behalf of Users when they join an Organization.

3.2 Information obtained from a variety of inquiries:

(1) To respond to various inquiries;

(2) To provide information (including advertising) from Monoxer.

3.3 Information acquired at events or from business partners (including prospective customers):

(1) To provide information (including advertising) and other business communications from Monoxer;

(2) For seasonal and other ceremonial greetings.

3.4 Information about applicants for employment:

(1) To select employees for recruitment activities;

(2) To make contact related to employment.

3.5 Information about Monoxer officers and employees:

(1) For personnel management work and internal procedures.

3.6 Information on shareholders or share option holders, etc. of the Company:

(1) To manage shareholders and to comply with procedures required by the Companies Act and other laws and regulations.

3.7 Monoxer may use personal information for purposes incidental to the purposes described in the preceding items.

Additionally, with regard to Section 3.1.3, when Users join an Organization, their memory based on previous learning may be provided to that Organization. Specifically, the information that Users have memorized and the information that is related to the information that they have memorized will be provided to the Organization based on past learning only when the Organization that a User has joined has configured it as information to be memorized or when the Organization Manager has added it as information to be memorized after the User has joined the Organization. If Users do not wish to provide their memory based on past learning to the Organization they join, create a new ID and join the Organization with the newly created ID. Memory is tied to and managed by this ID, so by using a newly created ID, memory based on past learning will no longer be provided to the Organization.

4. Use of Personal Information

4.1 We will not handle personal information beyond the scope necessary to achieve the purpose of use without the consent of the individual, except as permitted by the Personal Information Protection Act or other applicable laws and regulations. However, this shall not apply in the following cases:

(1) When required by law;

(2) When it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the individual;

(3) When it is particularly necessary to improve public health or to promote the sound growth of children and it is difficult to obtain the consent of the individual;

(4) When it is necessary to cooperate with a government agency, a municipality, or a party entrusted by either a government agency or municipality to execute affairs prescribed by law, and obtaining the consent of the individual is likely to impede the execution of the affairs concerned;

(5) When personal data (This refers to the term defined in Article 16.3 of the Personal Information Protection Act.) is provided to an academic research institution, etc., and it is necessary for said academic research institution, etc. to handle said personal data for academic research purposes; (including cases where part of the purpose of handling said personal data is for academic research purposes, and excluding cases where there is a risk of unjustified infringement of the rights and interests of individuals).

4.2 Monoxer will not use personal information in a manner that may encourage or induce illegal or improper acts.

5. Appropriate Acquisition of Personal Information

5.1 Monoxer will acquire personal information in a proper manner and will not acquire personal information through deceit or any other improper means.

5.2 Monoxer will not acquire any special care-required personal information (as defined in Article 2, Paragraph 3 of the Personal Information Protection Act) without obtaining the prior consent of the individual, except in the following cases:

(1) When any of items 1 through 4 of Section 4.1 applies;

(2) When acquiring the special care-required personal information from an academic research organization, etc., and such special care-required personal information must be acquired for the purpose of academic research (including cases where part of the purpose of acquiring said special care-required personal information is for academic research purposes, and excluding cases where there is a risk of unjustified infringement of the rights and interests of individuals) (This is limited to cases where said business operator handling personal information and said academic research institution, etc. jointly conduct academic research.);

(3) When said special care-required personal information is disclosed by the individual, a government agency, a municipality, an academic or research institution, etc., a person listed in each item of Article 57, Paragraph 1 of the Personal Information Protection Act, or any other person specified by the rules of the Personal Information Protection Commission;

(4) When acquiring special care-required personal information that is evident in its external appearance by seeing or photographing the individual;

(5) When being provided with the special care-required personal information from a third party, and said provision by said third party corresponds with any of the items of Section 8.1.

5.3 When Monoxer receives personal information from a third party, we will confirm the following items as stipulated by the Rules of the Personal Information Protection Commission. However, this excludes cases in which the provision of personal information by the third party falls under any of the items in Section 4.1 or Section 8.1:

(1) The name and address of said third party, and for a corporate body, the name of its representative (for a non-corporate body having appointed a representative or administrator, the name of said representative or administrator);

(2) Circumstances under which said personal information was acquired by said third party.

6.  Secure Control of Personal Information

Monoxer supervises our employees as necessary and appropriate to ensure that personal information is securely controlled against risks such as loss, destruction, falsification, and leaks of personal information. In the event that we outsource all or part of the handling of personal information, we will provide the necessary and appropriate supervision to ensure the security of personal information at the outsourced company. The outline of the security control measures concerning personal data (defined in Article 16.4 of the Personal Information Protection Act) held by Monoxer shall be the formulation of a basic policy, the establishment of rules concerning the handling of personal data, the implementation of organizational, personnel, physical, and technical security control measures, and an understanding of the external environment. Monoxer will provide you with the specific details of the security control measures without delay when you contact us through the contact point in Section 16.1.

7. Reporting, etc. in the Event of a Leak

In the event of a leak, loss, or damage of personal information handled by Monoxer, Monoxer will report to the Personal Information Protection Commission and notify the individual in accordance with the provisions of the Personal Information Protection Act.

8. Provision to Third Parties

8.1 Monoxer will not provide personal information to third parties without obtaining the prior consent of the individual, except in cases falling under any of the items in Section 4.1. However, the following cases do not fall under the provision of personal information to third parties as stipulated above:

(1) When personal information is provided in conjunction with the outsourcing of all or part of the handling of personal information within the scope necessary for the achievement of the purpose of use;

(2) When personal information is provided as a result of the succession of business due to merger or other reasons;

(3) When personal information jointly used with a specific person is provided to that specific person, and when this fact, the items of personal information jointly used, the scope of the joint users, the purpose of use by the users, and the name and address of the person responsible for managing the personal information, and in the case of a corporation, the name of its representative, are notified to the person or made readily available to the person in advance.

8.2 Notwithstanding the provisions of Section 8.1, in cases falling under any of the items of Section 4.1 and in cases where Monoxer provides personal information to third parties located in foreign countries other than those specified below, we shall obtain the prior consent of the individual authorizing the provision of the personal information to third parties located in foreign countries:

(1) Third parties located in countries designated by the Personal Information Protection Commission Regulations under Article 28 of the Personal Information Protection Act (hereinafter referred to as “Designated Countries”);

(2) Among third parties located in foreign countries other than the Designated Countries, those who have established a system that conforms to the standards established by the Rules of the Personal Information Protection Commission as necessary to continuously take measures with regard to the handling of personal information and that correspond to the measures (hereinafter referred to as the “Corresponding Measures”) required to be taken by business operators handling personal information.

8.3 When obtaining the consent of the individual to provide information to a third party located in a foreign country in accordance with Section 8.2, the following information shall be provided to the individual. However, in cases where the first item cannot be specified, the following information shall be provided in lieu of the first and second items: the fact that the first item cannot be specified and the reason thereof, and any information that can be used as a reference for the person in lieu of the first item:

(1) The name of said foreign country;

(2) Information on systems for the protection of personal information in said foreign country;

(3) Information on measures taken by said third party to protect personal information (if said information cannot be provided, a statement to that effect and the reason).

8.4 In the event that personal information is provided in accordance with Section 8.2.2, Monoxer will take the necessary measures to ensure the continuous implementation of the Corresponding Measures by the third party in accordance with laws and regulations, and will provide information regarding such necessary measures to said individual upon request by said individual.

8.5 When Monoxer provides personal information to a third party, Monoxer will create and preserve records in accordance with Article 29 of the Personal Information Protection Act.

8.6 When receiving personal information from a third party, Monoxer shall perform the necessary confirmation in accordance with Article 30 of the Personal Information Protection Act, and shall prepare and preserve records related to said confirmation.

9. Disclosure etc. of Personal Information etc.

9.1 When Monoxer receives a request from an individual for disclosure of personal information, notification of the purpose of use, or disclosure of records of provision of personal information to third parties (hereinafter collectively referred to as “disclosure, etc.”) in accordance with the provisions of the Personal Information Protection Act, Monoxer shall disclose the information to the individual without delay after confirming that the request is made by the individual themselves (if the personal information in question does not exist, Monoxer shall notify the individual to that effect). However, this shall not apply to cases in which Monoxer is not obligated to disclose the information under the Personal Information Protection Act or other laws and regulations. Please note that a handling fee (1,000 yen per case) will be charged for the disclosure of personal information.

9.2 The provisions of the preceding paragraph shall apply mutatis mutandis to the record of provision to a third party made in accordance with Section 8.5 and the record of provision from a third party made in accordance with Section 8.6 concerning personal information in which the person is identified. However, the provisions regarding fees are excluded.

10. Correction of Personal Information, etc.

When Monoxer is requested by an individual to correct, add, or delete their personal information (hereinafter referred to as “revisions, etc.”) based on the provisions of the Personal Information Protection Act for reasons that the personal information is not correct, Monoxer shall, upon confirming that the request is made by the individual themselves, conduct the necessary investigation without delay to the extent necessary to achieve the purpose of use of the personal information, and based on those results, Monoxer shall make revisions, etc. to the content of the personal information and notify the individual to that effect (if a decision not to make such revisions, etc. is made, the individual shall be notified to that effect). However, this shall not apply to cases in which Monoxer is not obligated to make revisions, etc. of the information under the Personal Information Protection Act or other laws and regulations.

11. Suspension of Use of Personal Information, etc.

11.1 When Monoxer receives a request from an individual to cease use, erase, or cease provision to a third party of their personal information in accordance with the provisions of the Personal Information Protection Act (hereinafter collectively referred to as “cease use, etc.”), Monoxer shall, without delay, cease use, etc. of the personal information or retained personal data after confirming that the request is made by the individual themselves and notify the individual to that effect. However, this shall not apply to cases in which Monoxer is not obligated to cease use, etc. of the information under the Personal Information Protection Act or other laws and regulations.

11.2 User information, including personal information, acquired by Monoxer as a result of the User’s use of the Service will not be deleted or its use suspended, etc., even if the Application is deleted. If you wish to stop using the Application, or if you wish to have Monoxer stop acquiring or using your user information, please contact the inquiry desk described in Article 16. However, please note that if a User belongs to an Organization, Monoxer may not be able to respond at its sole discretion.

12. Provision of Personal Related Information to Third Parties

12.1 When personal related information (meaning those set forth in Article 2, Paragraph 7 of the Personal Information Protection Act, and limited to those that constitute the personal information database, etc. set forth in Article 16, Paragraph 7 of the same Act; the same shall apply hereinafter.) has been thought to have been obtained by a third party as personal data, Monoxer shall not provide said personal related information to any third party without first confirming the following matters in accordance with the rules of the Personal Information Protection Commission, except in the cases listed in each item of Section 4.1:

(1) The consent of the individual has been obtained to allow said third party to receive the personal related information from Monoxer and acquire it as personal data that identifies the individual;

(2) In the case of provision to a third party located in a foreign country, when the consent of the individual set forth in the preceding item is to be obtained, the system for the protection of personal information in the foreign country, measures taken by the third party to protect personal information, and other information that should be of reference to the individual shall be provided to the individual in advance as prescribed by the rules of the Personal Information Protection Commission.

12.2 When Monoxer provides personal related information to a third party, Monoxer shall create and preserve records in accordance with Article 31 of the Personal Information Protection Act.

12.3 When receiving personal related information from a third party, Monoxer shall perform the necessary confirmation in accordance with Article 31 of the Personal Information Protection Act, and shall create and preserve records related to this confirmation.

13. Handling of Pseudonymized Information

13.1 When creating pseudonymized information, (meaning those set forth in Article 2, Paragraph 5 of the Personal Information Protection Act, and limited to those that constitute the Pseudonymous Processed Information Database, etc. set forth in Article 16, Paragraph 5 of the same Act. The same shall apply hereinafter.) Monoxer shall process personal information in accordance with the standards set forth in the Rules of the Personal Information Protection Commission.

13.2 When Monoxer has created the pseudonymized information or obtained the pseudonymized information and deleted information, etc. pertaining to said pseudonymized information (meaning those set forth in Article 41, Paragraph 2 of the Personal Information Protection Act. The same shall apply hereinafter.), Monoxer shall take measures for the secure control of the deleted information, etc. in accordance with the standards prescribed by the Rules of the Personal Information Protection Commission as those necessary to prevent the leakage of the deleted information, etc.

13.3 Monoxer shall comply with the following provisions with respect to pseudonymized information (Limited to information that is personal information. The same shall apply hereinafter in this Section 13.3):

(1) Notwithstanding the provisions of Section 4.1, Monoxer shall not handle pseudonymized information beyond the scope necessary to achieve the purpose of use, except as required by law;

(2) If the purpose of use of the pseudonymized information is changed, Monoxer shall promptly announce the new purpose of use;

(3) Notwithstanding the provisions of Sections 8.1 through 8.3, Monoxer shall not provide personal data that is pseudonymized information to any third party, except as required by law. However, the cases listed in each item of Section 8.1 do not fall under the provision of personal data to third parties as set forth above;

(4) In handling the pseudonymized information, Monoxer shall not collate such pseudonymized information with other information in order to identify the individual whose personal information was used to create such pseudonymized information;

(5) In handling pseudonymized information, Monoxer will not use the contact information or other information contained in said pseudonymized information to make telephone calls, send postal or letter mail, send telegrams, faxes, or electromagnetic transmissions, or visit the residence of a customer;

(6) The provisions of Article 7 and Articles 9 through 11 shall not apply to pseudonymized information.

13.4 Monoxer shall comply with the following requirements with respect to pseudonymized processed information (excluding information that is personal information. The same shall apply hereinafter in this Section 13.4):

(1) Monoxer will not provide pseudonymized information to third parties, except as required by law. However, the cases listed in each item of Section 8.1 do not fall under the provision of personal data to third parties as set forth above;

(2) Monoxer will provide necessary and appropriate supervision to our employees to ensure the secure control of the pseudonymized information against risks such as leaks of pseudonymized information. In the event that Monoxer outsources all or part of the handling of pseudonymized information, Monoxer shall provide the necessary and appropriate supervision to ensure the security of personal information at the outsourced company;

(3) In handling pseudonymized information, Monoxer shall not acquire deleted information, etc. to identify the individual whose personal information was used to create said pseudonymized information, nor shall Monoxer collate said pseudonymized information with any other information;

(4) In handling pseudonymized information, Monoxer will not use the contact information or other information contained in said pseudonymized information to make telephone calls, send postal or letter mail, send telegrams, faxes, or electromagnetic transmissions, or visit the residence of a customer;

14. Handling of Anonymously Processed Information

14.1 When creating anonymously processed information, (meaning those set forth in Article 2, Paragraph 6 of the Personal Information Protection Act, and limited to those that constitute the Anonymously Processed Information Database, etc. set forth in Article 16, Paragraph 6 of the same Act. The same shall apply hereinafter.) Monoxer shall process personal information in accordance with the standards set forth in the Rules of the Personal Information Protection Commission.

14.2 When Monoxer has created anonymously processed information, Monoxer shall take measures for its secure management in accordance with the standards set forth in the rules of the Personal Information Protection Commission.

14.3 When Monoxer has created anonymously processed information, Monoxer shall publicly announce the items of information concerning individuals contained in such anonymously processed information, as stipulated by the rules of the Personal Information Protection Commission.

14.4 When Monoxer provides anonymously processed information (including those created by us and those provided by a third party. The same shall apply hereinafter unless otherwise stipulated) to a third party, Monoxer shall, pursuant to the Rules of the Personal Information Protection Commission, publicly announce in advance the items of information concerning individuals included in the anonymously processed information that will be provided to the third party and the method of providing such information, and shall indicate to the third party that the information pertaining to such provision is anonymously processed information.

14.5 In handling anonymously processed information, Monoxer shall not (1)collate anonymously processed information with other information in order to identify the individual whose personal information was used to create the anonymously processed information, or (2) acquire ([2] is only in respect to said anonymously processed information provided by a third party) information regarding descriptions or personal identification codes deleted from said personal information or the processing method used in accordance with the provisions of Article 43, Paragraph 1 of the Personal Information Protection Act.

14.6 Monoxer shall take the necessary and appropriate measures for the secure management of anonymously processed information, handle complaints concerning the creation or other handling of anonymously processed information, and take other necessary measures to ensure the appropriate handling of anonymously processed information, and shall make efforts to publicly announce the details of such measures.

15. Use of External Transmission Tools, etc.

15.1 The Monoxer website or the Service uses cookies, etc. (hereinafter collectively referred to as “external transmission tools”) from tools or advertising services provided by third parties. These technologies help us understand how our website or the Service is being used, contribute to improving the User experience or the Service, or deliver advertisements that are optimized for the User and measure their effectiveness. Users who wish to disable external transmission tools may do so by modifying their web browser settings or, for some external transmission tools, by accessing the publisher's opt-out page. However, if you disable external transmission tools, you may not be able to use certain features of our website or the Service. Please refer to “About External Transmission Tools” for information on our use of external transmission tools.

15.2 Users may sign in to the Service using their Google account. In doing so, the user may display their email address and name on the Service via the Google API. Monoxer shall use such information only for the purpose of confirming registration information for the Service or creating a new account, and shall not use this information for any other purpose.

15.3 The Service is built on servers provided by Google, and Monoxer will transfer user information to such servers and use it within the scope of the purpose of use.

15.4 When using the speaking function of the Service, the voice data may be sent directly to a third party for the purpose of using the voice-to-text conversion function in a service provided by the third party. The third party will only use the audio data sent to it for the purpose of converting it into text and evaluating pronunciation, and such audio data will not be stored on the third party's service.

16. Inquiries

16.1 For requests for disclosure, revisions, cease of use, etc., opinions, questions, complaints, and other inquiries regarding the handling of personal information, please use the contacts listed below.

Sumitomo Fudosan Iidabashi Ekimae Building 7F, 3-8-5 Iidabashi, Chiyoda-ku, Tokyo 102-0072
Monoxer, Inc.
Kotaro Takeuchi, Personal Information Protection Manager,
Direct inquiries to:
E-mail : info@monoxer.com

16.2 If you wish to request disclosure, revisions, etc. or cease of use of your personal information, we will send the prescribed form (Personal Information Inquiry Application Form) to the address you have provided us. Please fill in the required information and send the following documents to the address below.

What to send:

(1) Personal Information Inquiry Application Form
Please fill out the following information on the prescribed form.

(a) Your name, address, telephone number and personal seal;

(b) Date of request;

(c) Information to identify the personal information for which disclosure, revisions, etc. or cease of use, etc. are requested.

(2) Identification documents for you or your proxy

<When you are applying>
One copy of your driver's license, passport, health insurance card, or residence card

<When your proxy is applying>
A letter of attorney indicating your proxy is acting on your behalf
One of the following documents: a certificate of the seal impression of the person whose name is affixed to the letter of attorney, or a document verifying the identity of your proxy.

(3)Fee
1,000 yen (for disclosure etc. only)

Send to:
Sumitomo Fudosan Iidabashi Ekimae Building 7F, 3-8-5 Iidabashi, Chiyoda-ku, Tokyo 102-0072
Monoxer, Inc.
Kotaro Takeuchi, Personal Information Protection Manager

* Requests made by a proxy will be limited to the following circumstances:

Legal proxy of a minor or an adult ward

A proxy authorized by the individual to make requests for disclosure etc., revisions, etc. or cease of use, etc.

16.3 Upon receipt of a request based on Section 16.2, Monoxer shall conduct the necessary investigation and provide a response within two weeks in writing, by providing an electromagnetic record, or by any other method requested by the person concerned, or disclose the information in writing should it be difficult to disclose the information by the method requested by the person concerned.

17. Continuous Improvement

Monoxer shall review the operational status of the handling of personal information as necessary and endeavor to continuously improve this Privacy Policy, and may make changes to it as needed.

Established: July 1, 2017
Revised: March 1, 2019
Revised: March 1, 2023
Revised: December 1, 2023
Revised: February 26, 2024


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